Judicial Corner: ASMT-12 closes scrutiny proceedings department cannot reopen the same issue through DRC-01A or DRC-01.(02.02.2026)

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ASMT-12 closes scrutiny proceedings department cannot reopen the same issue through DRC-01A or DRC-01. {Periyasamy Karthikeyan vs State Tax Officer W.P.(MD) No. 3049 of 2025 Madras High Court (Madurai Bench) | Order dated 06.01.2026}

Facts

  • Department issued ASMT-10 during scrutiny.
  • Taxpayer gave explanation with reconciliation.
  • Officer accepted it and issued ASMT-12 (closure).
  • Later, department again issued DRC-01A and DRC-01 on the same issue.

Issue

Whether the department can issue DRC-01A / DRC-01 after issuing ASMT-12 for the same discrepancy already examined in scrutiny proceedings?

Held

  • Once the taxpayer’s reply to ASMT-10 is accepted, proceedings stand concluded under Section 61(2).
  • Issue of ASMT-12 amounts to final closure of scrutiny.
  • After such closure, no further action can be taken on the same discrepancy.
  • Issuing DRC-01A or DRC-01 for the same issue is without jurisdiction.
  • Reopening the matter amounts to violation of statutory finality.
  • Accordingly, DRC-01A and DRC-01 were quashed.